ESR Response to the Digital Omnibus on Data, Cybersecurity & Privacy Please find below a summary of the European Society of Radiologys (ESR) response to the European Commissions Digital Omnibus on AI. The full response is provided in the attachment. The ESR is committed to maintaining constructive dialogue with the Commission and other stakeholders moving forward.
ESR
European Society of Radiology
NGO · Austria · EU Transparency Register 478131313572-40
12
positions filed
in the 665 files tracked
9
legislative files
of 665 tracked
7
with a full position paper
attached to a submission
Counts here are a floor, never a total: they cover the 665 consultation files tracked so far (57,774 submissions, mostly 2021–26), so an organization's real filing history is larger, not smaller.
Who they are
Among the 410 trade unions and professional associations on this site, they rank #62 by legislative files engaged, a count of participation, not a measure of influence.
1.2
declared lobbying FTE
self-declared
–
declared costs / yr (floor)
2
EP accreditations
as declared to the register
2014
in the register since
Declares membership of
- Founding member of the Alliance for MRI
- Member of the European Medicines Agency Healthcare Professionals’ Organisations Working Group (EMA HCP WG)
- Member of IHE Europe – Integrating the Healthcare Enterprise
- Member of the International Society of Radiology (ISR)
- Member of the European CanCer Organisation (ECCO)
- BioMed Alliance →
- EC eHealth Stakeholder Group
- EC HTA Stakeholder Network
- Member of the European Health Alliance on Alcohol (EHAA)
Self-declared to the EU Transparency Register (snapshot 14 Oct 2026).
- Register category
- Trade unions and professional associations
- Head office
- Vienna, Austria
Self-declared to the EU Transparency Register (snapshot 14 Oct 2026); cost bands are floors, not audited totals. Reused under Commission Decision 2011/833/EU.
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Their record over time
European Society of Radiology filed 12 positions between 6 Jan 2021 and 3 Aug 2026, across 9 of the 665 legislative files tracked here, attaching a full position paper 7 times.
2021 · 4 filed2022 · 1 filed2025 · 3 filed2026 · 4 filed
What they argued
Please find below a summary of the European Society of Radiologys (ESR) response to the European Commissions Digital Omnibus on AI. The full response is provided in the attachment. The ESR is committed to maintaining constructive dialogue with the Commission and other stakeholders moving forward.
The European Society of Radiology (ESR) welcomes the Digital Omnibus proposal, the initiative of the Commission to simplify obligations in the Artificial Intelligence Act, and it is eager to contribute to the call for feedback on the proposal.
The European Society of Radiology (ESR), representing over 140,000 members both in and out of Europe, welcomes the European Commissions proposal to simplify EU rules for medical devices and in vitro diagnostics.
The European Society of Radiology (ESR) welcomes the opportunity to submit a call for evidence on the evaluation of the Medical Devices Regulation. The evidence that follows is based on the experience prevalent in interventional radiologist units, which have been more affected by the shortcomings of the MDR.
The European Society of Radiology (ESR) welcomes the European Commissions proposal for the next Multiannual Financial Framework (MFF) and the ambition to double the Horizon Europe budget under the next Horizon Europe programme for the period 2028-2034. ESR fully supports the ECs recognition of research and innovation as central pillars to strengthen Europes competitiveness, resilience and societal wellbeing.
The European Society of Radiology (ESR) welcomes the European Commission’s initiative to create the first AI regulation worldwide. However, it recognises the importance of taking into account the specificities of the healthcare field, which require a specific regulatory approach for AI, complementing the currently proposed horizontal, cross-sector regulation.
The European Society of Radiology (ESR) welcomes the European Commission’s proposal for the European Health Data Space (EHDS), a crucial way towards ensuring patient-centered healthcare, by using patient data to continuously improve patient care and health outcomes.
The European Society of Radiology (ESR) welcomes the European Commission initiative on a Council Recommendation for cardiovascular health checks and supports its objective of strengthening early detection and prevention through a coordinated and evidence-based approach across Member States.
The European Society of Radiology (ESR) warmly welcomes the European Commission’s proposal to reinforce the mandate of the European Centre for Disease Prevention and Control (ECDC). The COVID19 epidemic has exacerbated the need for establishing adequate surveillance, preparedness, early warning and response measures for future pandemics.
The European Society of Radiology (ESR) welcomes the European Commission’s proposal to determine a clear framework for the deployment of the activities of the European Medicines Agency (EMA) to monitor and mitigate potential and actual shortages of medicinal products and medical devices.
The European Society of Radiology welcomes the European Commission’s proposal for a stronger and more comprehensive legal framework to react rapidly and trigger the implementation of preparedness and response measures to cross-border health threats. Medical imaging maintains an essential role in the diagnostic process of COVID19.
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